[NORMAL] Research Hazardous Waste Training Refresher

Research Hazardous Waste

Training Refresher

January 14, 2015

Jen Dallaire, VAMHCS GEMS Coordinator

References



40 CFR 261-299 (EPA Regulations)



COMAR 26.13.01-.13 (MDE Regulations)



VAMHCS Research and Development

Disaster/Emergency Preparedness Plan, SOP

151/R&D-001



VAMHCS Research and Development Safety

Plan, SOP 151/R&D-002



VAMHCS Research Service Laboratory Safety

Hazardous Waste



What is it?



How do I manage and store it?



How do I get rid of it?



What do I do if it spills?



How can I prevent [some of] it?

WHAT IS IT?

What is Hazardous Waste?

◦ Is the chemical expired?

◦ Is the chemical still being used in your current process?

◦ Do you have newer versions of the same chemicals that you currently use?

◦ Did You Discard of this Material in a Satellite Accumulation Area near Your Workstation?

◦ Do You have clean-up Materials from a Spill?

Specifically, What is Hazardous Waste?

(40 CFR 261.31 and .33)

Listed waste is waste that has been identified by

the EPA to be hazardous; and subsequently put on one of the following lists:

F-Lists – Wastes defined by the process that

generates them (Non-Specific Sources). Common VAMHCS waste that fit this category include: Xylene, Methanol, and acetone.

P-Lists – Waste listed because they have acute

toxicity and/or reactivity. Examples include: epinephrine (P042) and nicotine (P075)

U-Lists – Waste listed for corrosivity or

ignitability. Examples include: ethylene oxide (U115), chemotherapy drugs such as

chloroambucil (U035), and unused solvents such as xylene (U239) and methanol (U154)

(40 CFR 261.21-.24)

Characteristic waste is waste that has not been

explicitly identified but may still be hazardous if it exhibits one of the following characteristics:

Ignitability: Any waste with a flash point of <140°F

(60°C). Examples: waste paint, solvents, potassium permanganate.

Corrosivity: Any liquid with a pH less than 2 or

greater then 12.5. Examples: sodium hydroxide, strong acids and bases.

Reactivity: Any material that can readily explode

or undergo violent reactions under “normal” conditions. Or any material that can cause explosions, toxic fumes, gases or vapor when mixed with water. Examples: Picric acid, lithium sulfur batteries.

Toxicity: Wastes that contain concentrations of

specific toxic chemicals above regulatory

Listed Hazardous Waste

Examples

1/9/2015

U Listed

-Formaldehyde (U122) -Formic Acid (U123) -Phenol (U188)

-Ethylene oxide (U115)

-Acetone (U002) [Unused Solvents] -Xylene (U239) [Unused Solvents] -Methanol (U154) [Unused Solvents]

-Chloroambucil (U035) [Chemotherapy drug]

P Listed

Listed Hazardous Waste

Examples

F-Listed

–Xylene (F003) [spent non-halogenated solvents]

-Methanol (F003) [spent non-halogenated solvents]

-Acetone (F003) [spent non-halogenated solvents]

Characteristic Hazardous Waste

Examples

Ignitable

Waste paint,

Solvents,

Potassium Permanganate

Corrosive

Strong Acids

Strong Bases

Sodium Hydroxide

Reactive

Picric Acid,



Lithium Sulfur Batteries

TOXIC



Silver



Mercury

Lead

HOW DO I MANAGE

AND STORE IT?

What’s Wrong with these Pictures?

How to Fix what’s wrong with these

Pictures?

Label All Hazardous waste storage areas

What if I don’t label my Containers?



Risk to Human Health & Lab Environment



Your Waste Cannot leave your Lab



Approximately $2000 per “unknown waste”

from Your Service and Your Project for RCRA

Waste Characterization Sampling & Analysis

Satellite Accumulation Area/Point management

SATELLITE

ACCUMULATION POINT

Room Number: __________

Service: ___________ _{Keep waste containers closed when waste is not being}

added.

Label waste with the material name and the words “Hazardous Waste”. Examples: Hazardous Waste, Xylene; Waste Alcohol.

Date the container with the day that the waste was first added.

Segregate different waste streams. For Example separate flammables from non flammables, pesticides from corrosives, etc.

Label storage area with the following wording – Satellite Accumulation Point, Room Number, Service. (Please note that you cannot store more than 55 gallons of waste or 1 quart of P listed waste at anytime.)

Provide secondary containment for liquids to contain any possible spills.

Quick Reference Guide- Satellite Accumulation Area/Point (SAA)/(SAP)

Requirements

Waste Location Away from floor drains & within line of sight and under the control of the operator generating the waste.

Container Management • Containers must be in good condition, compatible with the contents inside, and remain closed

• Replace/repair damaged containers

Labeling requirements • “Hazardous Waste” and the Chemical Name. Also label Area where waste is stored “Satellite Accumulation Point/Area”

Segregation • Separate and store by hazardous characteristics

Storage amounts & time limits •Up to 55 gallons of hazardous waste OR 1 quart of P-Listed hazardous waste

•**When you reach two full black containers (~18 gal each), Complete a waste turn-in and contact us for pick up

Empty Containers • Empty containers can be disposed of as solid waste.

• Containers formerly holding P-Listed must be disposed of as Hazardous Waste.

Waste Turn-In • Use Waste turn-in Form.

• Contact Safety Department : Jen Dallaire , GEMS 410-642-2411 x5227 or John Barnes, IH Baltimore x4014

How Long Can I Store It and How

Much Can I Store?

•

55 gallons of hazardous waste OR 1 quart of P-Listed

hazardous waste in your work area.

•

P-Listed waste is “Acutely Hazardous” and therefore must

be handled more stringently.



You must contact the Safety Department

prior to reaching this storage limit for proper

turn-in.

OR

55 gallons One Quart

Need Hazardous Waste Storage?

1/9/2015

• Are You Storing hazardous waste in Fume Hoods? • Are You Overloaded with Chemicals in Your Lab?

Dos and Do Nots of Hazardous Waste

Storage



Do:

 Store Away from floor drains

 Store Within the line of sight of staff working in the area  Label as Satellite Accumulation Area

 For a large amount of hazardous waste (18 gal or 55 gal drum) store on a secondary containment pallet

Do Not:

Dispose of down the drain

What if the Containers are Empty?



Empty Containers:

 Empty is defined as

:

 Containers that once held solid or liquid hazardous waste that now contain less then 3% of the original hazardous material (i.e only a small amount of solid or liquid residue is left in container)

 Gaseous containers are empty when their pressure approaches atmospheric pressure.

**NOTE: If a container once held a P-Listed hazardous waste the

container is still considered a hazardous waste even if it is empty.**

HOW DO I GET RID OF

IT?

Chemical Disposal/Waste Turn-In Form

Example

1/9/2015

VA Chemical Disposal/Waste Turn-In Form

This form should be submitted by email to IH John Barnes: john.a.barnes@va.gov and GEMS Coordinator: Jennifer.Dallaire@va.gov

SDS access: http://vaww.vamhcs.med.va.gov/

DATE: ROOM NUMBER: PERSON TO CONTACT: NAME OF PI IN CHARGE:

PHYSICAL REASON FOR DISPOSAL HAZARD

CHEMICAL NAME STATE QUANTITY DISPOSAL FREQUENCY INFORMATION

physical state gallons, mL, L, etc. reason for disposal Disposal Freq. hazard information

liquid analytical waste one time only flammable solid out of date, no longer used yearly corrosive compressed gas lab cleanout & closure quarterly toxic

none - please explain monthly oxidizer weekly potentially explosive daily other

Hazardous Waste Turn-In Example –

Filled In

DATE: 1/5/2015 ROOM NUMBER: VA Baltimore, 3C-105

PERSON TO CONTACT: Carol Fowler - carol.fowler@va.gov NAME OF PI IN CHARGE: Jeffrey Mason

PHYSICAL REASON FOR DISPOSAL HAZARD CHEMICAL NAME STATE QUANTITY DISPOSAL FREQUENCY INFORMATION

FROM YOUR SDS: FROM YOUR SDS:

1. HPLC Waste (30% methanol, 69% water, liquid 4 Liters analytical waste one time only flammable 0.5% formic acid, 0.5% ammonium Formate

2. HPLC Waste (30% methanol, 69% water, liquid 4 Liters analytical waste one time only flammable 0.5% formic acid, 0.5% ammonium Formate

3. HPLC Waste (30% methanol, 69% water, liquid 4 Liters analytical waste one time only flammable 0.5% formic acid, 0.5% ammonium Formate

4. 10% acetic acid, 50% ethanol, 38% water, liquid 3 Liters analytical waste one time only flammable 1% formaldehyde, 1% silver nitrate

How to Get Rid of Your Hazardous

Waste

Turn-In procedure:

1.

Complete a“Chemical Disposal/Waste Turn-In” Form

prior to pick-up.

2.

Schedule waste pick up with:

Jen Dallaire, VAMHCS GEMS Coordinator, (410) 642-2411 ext. 5227

John Barnes, PP Industrial Hygienist, (410) 642-2411 ext. 4014

**All Hazardous waste must be turned in to the

VAMHCS Safety Department**

WHAT DO I DO IF IT

SPILLS?

Spill Discovery & Response

Class I – A spill that can be

easily cleaned up by personnel

at the site

of the spill without

risk to personal safety or the

environment (typically

< 5

gallons

)

Class II – one which

can not be

easily cleaned up

or may endanger

human health or the environment.

Greater than 5 gallons

, or a spill

near a drain or surface water.

Class I Spill Response

1. Stop the leak and prevent the spill from spreading (Barrier) using the spill kits and proper PPE. [Refer to VAMHCS Research Service Laboratory Safety Manual , Chemical Spills Section (pages 9-10)]

2. Notify the VAMHCS Safety Department –

 John Barnes, IH (BT- ext. 4014)

 Emanuel Mbong (BT– ext. 4548)

 Jen Dallaire (PP-ext. 5227)

 Joe Fannon (PP – ext. 6915)

 Or call the USRO for after hour incidents.

3. Recover spilled product and clean up the affected area.

4. Place waste or used spill kit materials in a container for disposal as Hazardous Waste. Do not place clean-up materials in the regular trash cans.

Class II Spill Response

[Refer to VAMHCS Research Service Laboratory Safety Manual , Chemical Spills Section]

1. Remove any injured individuals when possible and make the spill area off limits to unauthorized personnel.

2. Notify the VAMHCS Safety Department –

 John Barnes, IH (BT- ext. 4014)

 Emanuel Mbong (BT– ext. 4548)

 Jen Dallaire (PP-ext. 5227)

 Joe Fannon (PP – ext. 6915)

 Or call the USRO for after hour incidents.

3. Remove all sources of ignition. No smoking, open flames, or equipment operation that could cause sparks or static.

4. Stop the leak and prevent the spill from spreading (particularly to drains) if possible using materials in the spill kits.

5. Begin steps to recover any spilled product and clean up the affected area if possible.

6. Stand by to inform and assist safety personnel. If necessary, the Fire Department or City Hazmat team may be notified, but this decision is to be

Spill Response Kits



Every VAMC Lab Should Have Spill clean up kits



R&D Stores Extra Spill Kits in 3C-101,3C-111, and

3C-127.



Types of Spill Kits include:

◦

Acid Neutralizer

◦

Base Neutralizer

◦

Formaldehyde

HOW DO I PREVENT

[SOME OF] IT?

 Do not order hazardous materials, chemical, or aerosols in bulk.

 Order chemicals in smaller quantities to avoid excess storage.

 Buy containers that are wider than taller

 Buy containers which minimize disposal problems

 re-fillable pressurized spray cans in place of single use aerosol

1/9/2015

 Before ordering hazardous chemicals see if anyone else in your work area has already ordered the material you need.

 Check with other services to see if they have chemicals to spare.

 Sort out non-hazardous waste from Hazardous

 Turn in waste when it is expired or no longer needed

 Effectively track hazardous chemicals and use oldest stock first

.

Stay Organized

Hazardous Waste costs $5.12 per pound for

disposal.

In CY 2009 the VAMHCS spent $74,394.76 on

Hazardous Waste disposal

Approximately 60% of that waste came from

research ($44,636.86)

1/9/2015

Drain Disposal

The following materials are not permitted to reach the environment

through the sewer system:

The following cannot be discharged through drain:

1) Flammable or explosive substances with a closed cup flashpoint of 140 degrees F 2) Hot liquids or vapors over 150 degrees F

3) Solids or viscous substances 4) Noxious substances

5) Pollutants creating toxic gases or toxic pollutants 6) Oils

7) Radioactive material, unless approved by radiation safety officer & GEMS Coordinator 8) Garbage

9) Acids or alkalies (<6 or >12)

More information:

http://cityservices.baltimorecity.gov/charterandcodes/Code/Art%2025%20-%20Sewers.pdf

Regulated Medical Waste (RMW)

“Cakes, Flakes, or Drips”

 Anatomical Material: Human or animal body parts, including tissues and

organs. Blood that is in a liquid or semi liquid state.

 A contaminated item that would release potentially infectious material in a

liquid or semi liquid state if compressed.

 Contaminated material: Feces of an individual diagnosed as having a disease

or an article that has come into contact with a known human pathogen.

 An infectious substance that is known or reasonably expected to contain a

pathogen and can cause disease in humans. (Pathogen: A microorganism, including bacteria, viruses, rickettsiae, parasites, and fungi, or other agent, such as prions, that can cause disease in humans or animals.)

 Microbiological laboratory waste

 Other potentially infectious material that is in a liquid or semi liquid state.

 Pathological and microbiological waste that contains blood or other

potentially infectious material

Regulated Medical Waste (RMW)

Special Notes for Research

Urine: Urine is not considered regulated medical waste. It is routine, non-infectious

waste that may be disposed of in the sanitary sewer.

Containers that held urine can be disposed of in the solid waste stream.

All regulated medical waste containers shall be designated as such by label.

All containers shall one of the following labels affixed to them (orange or red):

Containers shall be kept closed when not in use

Glass and hard plastic containers that do not fit the definition of RMW should be

disposed of in cardboard receptacles labeled ‘glass waste’ to prevent injury to staff handling the non-infectious waste stream.

Animal Researchers: If animals are taken to the 3rd floor for research purposes, all

associated waste (i.e. bedding, carcasses, soiled bench pads) must be contained in a sealed biohazard bag and returned to the animal facility for disposal. No animal waste shall be disposed of on the 3rd floor.

 Do not dispose of solid waste such as paper towels, paper, pizza boxes, coffee cups, newspapers, plastic containers, and food waste into

Regulated Medical Waste containers, unless these items have been saturated in blood.

 Materials with small droplets of blood on them shall not be disposed of in RMW. These items include: band aids, unsaturated gauze, and regular patient exam room waste.

 Non-contaminated gloves, by law, are NOT considered RMW, however if you are unsure if your gloves are contaminated with infectious material please dispose of them in the regulated medical waste containers

.

Universal Waste

 Legislation: Regulated by the EPA, 40 CFR 273 (stem from RCRA)  Definition: Federal Designated hazardous wastes that are so commonly

generated among industries that they were given less stringent guidelines in order to ease the regulatory burden and facilitate recycling.

 Types: Batteries, Pesticides, mercury containing equipment, and lamps

 Disposal: All of these materials are recycled when they are disposed of. If you have any batteries for disposal place them in 3C-111. If you have mercury containing

equipment please turn it in using the hazardous waste turn in form.

Baltimore VAMC Paper Recycling

Program started October 2014

White Paper Waste

Legislation: HIPAA

White paper waste that contains sensitive information in Shred-It

containers located through out the facility.

The material is picked up by a Shred-It representative and shredded on

station. The paper waste is then recycled.

Do not dispose of books, binders, or magazines

or other paper in this waste stream.

The VAMHCS saved over 1071

trees in FY 2009 with this

recycling program

CARDBOARD

Collecting Cardboard:

Only broken down/flat boxes may be placed in the recycling bins. Do not put any packing material in the bins. No boxes with food or biohazard residue.

Process:

Breakdown boxes Place in “Cardboard Only” Dumpsters Break down cardboard after shipments arrive. Leave all cardboard

outside laboratory doors and EMS will collect for Recycling. OR

Take the broken down boxes to the recycling dumpster located in the basement at the loading dock.

How can you participate???

Easy, follow the steps below:

1. When ink & toner are replaced, store the used containers in the same box that the new cartridges came in.

2. Label the cardboard box with: “Toner/Ink for Recycling.”

3. Store the used boxes in a central location such as: print room, fax room, or break room. 4. Turn boxes in:

a. BALTIMORE: Turn in boxes to Warehouse. Contact warehouse when you need a pick-up or give the boxes to them when they are making a pick-up or collecting a turn-in in your area. Warehouse will ship boxes to Perry Point when they have accumulated a

pallet.

General Information: All makes, models, and types of used toner & ink cartridges are

being recycled through the Perry Point warehouse.

INK & TONER

Cartridges

Double Check: Like Cardboard, ask the Warehouse staff that makes the pick up, what they do with the material.

Questions?